Taxpayers have long utilized trust arrangements for the transfer of wealth to beneficiaries or for the protection of assets from creditors. Generally, there is nothing nefarious about these types of arrangements. Rather,...more
A bedrock of IRS administrative practice has been the voluntary disclosure. Where an individual or business has not filed tax returns or believes they may have criminal tax exposure for prior actions, IRS procedures have...more
El 13 de marzo del 2018, el IRS anunció la terminación del Programa de Divulgación Voluntaria De Cuentas en el Extranjero (“OVDP”) desde el 28 de septiembre del 2018 (Notificación IR-2018-52). El OVDP ha estado disponible...more
On March 13, 2018, IRS announced the termination of the Offshore Voluntary Disclosure Program (OVDP) as of September 28, 2018 (Notice IR-2018-52). ...more
The IRS recently announced that it is ending its Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018. ...more
The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more
On March 13th, the Internal Revenue Service ("IRS") announced that the offshore voluntary disclosure program ("OVDP"), which was first launched in 2009 and modified several times, will close to new taxpayers after September...more
As I discussed in a prior blog post, if you have more than $10,000 in a foreign bank account, you are obligated to file Form 114 (commonly known as an FBAR). Failure to make this filing can result in significant civil...more
The U.S. Internal Revenue Service has just announced that it will end the Offshore Voluntary Disclosure Program (“OVDP”) on 28 September 2018. ...more
A significant number of US Taxpayers living overseas have become “unbankable” where they live because of high account servicing costs for local banks (Foreign Financial Institutions – also known as FFIs) caused by the...more
First, the Panama Papers, and now… the Paradise Papers. The Paradise Papers contain the names of approximately 31,000 US citizens, including entities, or persons with US addresses....more
If an individual or business owes federal taxes and does not have the current ability to pay these taxes, the IRS can “seller-finance” and offer a payment plan with the taxpayer. The primary benefit of a payment plan is that...more
The United States has a voluntary income tax reporting system. U.S. citizens, permanent residents, and businesses here must annually file income tax returns with the IRS, reporting their “worldwide income”, deductions, and...more
The South Carolina General Assembly approved a law in 2015 allowing the South Carolina Department of Revenue to offer an amnesty program to taxpayers in the state who have not filed tax returns and/or owe state taxes....more
Instituciones Financieras extranjeras (FFIs) y las autoridades fiscales de los países anfitriones le han proporcionado al IRS con una segunda ronda de informes de información sobre cuentas financieras mantenidas por los...more
It has been a busy year for developments in Alabama state taxation. In this tax alert we review many of the significant developments that have occurred over the last 12 months....more
Since 2009, the Internal Revenue Service has offered three different amnesty programs for taxpayers with undeclared foreign bank accounts. These programs, the current version of which is entitled the Offshore Voluntary...more